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The Medium Combustion Plants Regulations

Air Quality and Waste Unit Permitting Unit

Contents of Presentation

• What are the Medium Combustion Plants (MCP) Regulations?
• Objectives of the MCP Regulations
• Scope of the MCP Regulations
• Legislative Requirements and Timeframes
• Application & Permitting Structure
• Exemptions & Derogations
• Compliance & Reporting
• Regulatory Impact

What are the Medium Combustion Plants Regulations?

• Regulations transpose the Medium Combustion

Plants Directive which came into effect 25 November 2015.

• Transposition of the MCP Directive into national

laws is required.

• It introduces minimum requirements to regulate

emissions of NOx, SO2 and PM from small power plants and industrial installations.

• It places controls on combustion plants of rated

thermal input between 1MW and 50MW.

What is Rated Thermal input (RTI)?

• Terms you may be

familiar with:

– Power output – Fuel type and – Thermal efficiency

The rate at which fuel can be burnt at the maximum continuous rating of the combustion plant multiplied by the net heat value of the fuel expressed as Megawatts Thermal.

Examples of Rated Thermal input

• The regulation of (MCPs) combustion plants of between 1 and

50MWth – equating to electrical output broadly between 330kW and 17MW.

Source: Cummins Source: Wärtsilä Source: Global Sources

 

Objectives of the MCP Regulations

The EU aims to “achieve levels of air quality that do not result in unacceptable impacts on and risks to, human health and the environment’’. The purpose of this Directive, and the Regulations, is to regulate, and ultimately reduce: – Sulphur dioxide (SO2) – Nitrogen oxides (NOx) – Dust emissions

• The Regulations also lay down rules to

monitor but not regulate emissions of carbon monoxide (CO).

• No deterioration of air quality through

the use of MCPs is allowed.

Source: UNEP GRID-Adrenal

Scope of the MCP Regulations

• Various manufacturing and

industrial processes are specifically excluded from the requirements of the Directive, however stationary combustion plants are included.

• Regulations will mainly impact

installations who operate

– combustion plants to power or heat their facilities. – Energy-from-waste plants

Source: Johnston Boiler Company

Scope of the MCP Regulations

The impact will also not be limited to industrial facilities. Operators of large back-up generators or boiler plants could also be effected by the provisions.

Source: Rolls-Royce

Operators will need to keep the deadlines in mind in view of applicability

• f various provisions.

Source: Siemens

New and Existing MCPs

• Existing combustion plant -

combustion plant put into

• peration before 20 December

2018 or for which a permit was granted before 19 December 2017.

• New combustion plant -

combustion plant other than an existing combustion plant.

A distinction is made between new and existing installations.

Legislative requirements and Timeframes

For New MCPs the obligation to obtain a permit applies immediately. For Existing MCPs, the requirements are being phased:

• RTI > 5MW must be permitted by 1 January 2024;

and

• RTI≤ 5MW the deadline is 1 January 2029.

Permitting requirements Each operator of a MCP must be subject to a permit issued by ERA.

Application Structure

• A simple application form shall be implemented.
• An application for a permit with ERA shall be carried out using the

application form published by the Authority on its website.

• Application shall at least include information listed in Schedule I.

Details to be included:

– rated thermal input of the medium combustion plant, – type of the plant , – type and share of fuel, – date of the start of the operation, – sector of activity, – the expected number of operating hours.

Permit Structure

• In cases where a permit is required under

some

• ther

piece

• f

legislation, the

• bligations under these regulations shall be

incorporated into one permit.

• Permit

will include various

• perating

conditions, ELVs and reporting requirements.

• ERA may request a bank guarantee to ensure

compliance with the conditions laid down in a permit.

Legislative requirements and Timeframes

For New MCPs obligation to obtain a permit applies immediately. The strictest limits are placed on new MCPs as from 20 December 2018 Existing MCPs are subject to less strict limits, with a phased approach:

• RTI > 5MW are subject to emission limits from 1

January 2025; and

• RTI≤ 5MW will have to comply with emission limits

(generally the least strict limits of all) from 1 January 2030. Emission Limit Values

MCPs will have to comply with emission limit values for SO2, NOx and Dust.

Example of ELVs

1<RTI ≤ 5MW RTI < 5MW 1– 50MW 1– 50MW 1– 50MW Other than engines and gas turbines Other than engines and gas turbines Existing Engines and gas turbines Other than engines and gas turbines New Engines and gas turbines Gas oil Gas oil Gas oil Gas oil Gas oil SO2 ― ― ― ― ― NOx 200 200 120 (E) * 200 190 ** (E) 200 (GT) 75 (GT) Dust ― ― ― ― ―

Exemptions & Derogations

Exemptions on the basis of Operating Hours Existing MCPs which operate for less than 500 hours per year (on a rolling average) can be exempted from the emission limits provided that such plants comply with a 200mg/NM3 limit for particulates from solid fuel plants. New MCPs (with a 100mg/NM3 limit for particulates from solid fuel plant). Additional derogations apply until 1 January 2030 for:

• Plants over 5MW where at least 50% of useful heat produced is provided to district heating

systems;

• Solid biomass plant;
• Plant used to drive certain gas compressor stations; and
• Small and micro isolated systems.
• Derogations apply in the case of low-sulphur fuel and gaseous fuel plant suffering significant

interruptions to supply.

Exemptions & Derogations

Exception of imposing stricter ELVs

• In areas where there are

exceedances of Ambient Air Quality Regulations limit values, the Authority may consider applying more stringent limits on individual MCPs in these zones, provided that applying such limits would effectively contribute to a noticeable improvement of air quality.

Source: Huffington Post Source: earthtimes.org

Compliance & Reporting

• Monitoring requirements

– Periodic monitoring of ELV pollutants is a requirement.

• 1-20 MW: every 3 years or >20 MW: annually
• Reduced frequency if ≤ 500 hr/yr

– Continuous monitoring may be requested by the Authority – Initial monitoring is required within four months of the plant being permitted

• r from the date of the start of operation whichever is the latest.

– Plants applying secondary abatement equipment will require continuous monitoring of its effective operation – Alternative allowed for SO2 monitoring based on sulphur content of fuel

• Compliance Deadlines & Non-Compliances
• ELVs will apply immediately to all new plants from December 2018.
• Existing plants have until 2025 or 2030 to comply with Emission Limit Values

depending on capacity.

• Suspension of the permit and penalties may apply in the event of non-compliance.

Summary of Monitoring Requirements

Thermal Input First Measurement Pollutants Periodic Measurements MCPs Exempted MCPs 500 h/year 1MW≤ RTI ≤ 20 MW Within 4 months As set out in Schedule II & CO Every 3 years Every 1500 hours or 5 years RTI>20M W Annually Every 500 hours or 5 years

Reporting requirements

• The Regulations place a number of obligations on operators with respect to the

retention of data. Operators will be required to maintain proof of the permit being granted by the Competent Authority; emissions monitoring results; a record of

• perating hours and of the fuels used; and any malfunctions or breakdown of secondary

abatement equipment for at least ten years.

• The Authority is also obliged to report the data to the European Commission. The first

report being the submission of CO data in 2021.

‘’Member States shall submit a report to the Commission, by 1 January 2021, with an estimate of the total annual emissions

• f CO and any information available on the concentration of emissions of CO from medium combustion plants, grouped by fuel

type and capacity class.’’ ‘’Member States shall, by 1 October 2026 and by 1 October 2031, submit a report to the Commission with qualitative and quantitative information on the implementation of this Directive, on any action taken to verify compliance of the operation of medium combustion plants with this Directive and on any enforcement action for the purposes thereof.’’

• Review clauses are included in which the Commission can assess the need to regulate CO emissions

and the possibility of setting minimum energy efficiency requirements.

Operator Obligations

Obtain Permit

Monitor Emissions

Record & Report Emissions

Operators will need to ensure:

• They hold a permit for operational plant by the relevant

deadlines;

• Emissions are monitored and must demonstrate compliance

with the applicable emission limit values;

• Records of operation of the plant are kept for at least six

years to demonstrate compliance.

Fee Structure

Fee

Rated thermal input (MWTH)

≥1≤5 >5≤10 >10≤20 >20≤30 >30≤40 >40<50

Fee for new permit

€500 €800 €1,500 €2,700 €3,500 €4,500

Fee for transfer of

• wnership or

variationi

10 % of the application fee for new permit

Fee for renewal or surrender

25 % of the application fee for new permit

Fee for derogationii

40% of the application fee for new permit

[i]

Regulatory Impact

• ERA is in the process of commissioning a

study which will serve as a scoping exercise to gauge which and how such installations will be effected by the introduction of these regulations.

• ERA is engaging fully with all stakeholders

during the public consultation.

Feedback

MESDC and ERA welcome your comments on the Medium Combustion Plants Regulations, which is available on the Public Consultation section on the ERA website. You may wish to submit any comments by 12th December 2017 on the following email address: international.affairs@era.org.mt.

Permitting Unit

Thank you for your attention